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[DOCKET NUMBER Trial Court of Massachusetts =
CIVIL ACTION COVER SHEET || {
| The Superior Court
ee | n
PLAINTIFF(S): George W. Hodgetts, Individually and as Beneficiary of the Diarra counry
Middlesex
ADDRESS: 4110 Huntley Apartment Drive, Pelham, Alabama 35124
DEFENDANT(S) Julie Mequade Ladimer, Individually and as Trustee of The
emt
Dianne Blandon Parents Trust u/d/t 2/3/1997; And as Trusteeof The Dianne Hodgetts
a
ATTORNEY: ‘Cameron C. Pease Irrevocable Life Insurance Trust u/d/t December 4, 2019
ADDRESS: Goldman & Pease, LLC ADDRESS: Ladimer Law, 209 W. Central Street, Suite 3158
160 Gould St., Ste. 320 sec Natick, MA 01760 ~
Needham, MA 02494 a
BBO: 561908
TYPE OF ACTION AND TRACK DESIGNATION {see reverse side)
CODE NO. TYPE OF ACTION (specify) TRACK HAS A JURY CLAIM BEEN MADE?
A99 Other (specify) FE (lives NO
*If "Other" please describe: Trust and Estates
ee aint were ee
STATEMENT OF DAMAGES PURSUANT TO GL. c, 212, § 3A
The following is a full, itemized and detailed statement of the facts on which the undersigned plaintiff or plaintiff counsel relies to determine money damages. For
ithis form, disregard double or treble damage claims; indicate single damages only.
TORT.CLAIMS.
(attach additional sheets as necessary)
\A. Documented medical expenses to date:
1. Total hospital expenses 3/25/202.
2. Total doctor expense:
3. Total chiropractic expt
4. Total physical therapy expenses
5. Total other expenses (describe below) RECEIVED
Subtotal (
'B, Documented lost wages and compensation to date
‘C. Documented property damages to dated
D. Reasonably anticipated future medical and hospital expenses
E. Reasonably anticipated lost wages
F. Other documented items of damages (describe below)
|G. Briefly describe plaintiffs injury, including the nature and extent of injury:
TOTAL (A-F):$
CONTRACT CLAIMS
(attach additional sheets as necessary)
Provide a detailed description of claims(s):
Declaratory Judgment and Breach of Fiduciary Duty in connection with an Irrevocable Trust TOTAL: $ $500,000.00
-
- ‘
| Signature of Attorney/Pro Se Plaintiff: a a Date: 3/25/2021
'RELATED ACTIONS: Please provide the case number, case name, and Sounty of any telated actions pending in the Superior Court.
CERTIFICATION PURSUANT TO SJC RULE 1:18
| hereby certify that | have complied with requirements of Rule 5 of the Supreme Judicial Court Uniform Rules on Dispute Resolution (SUC.
Rule 1:18) requiring that | provide my clients with information about court-connected dispute resolution services and discuss with them the
advantages and disadvantages of the various methods of dispute resolution.
‘Signature of Attorney of Record: X ae ani
Date: 3/25/2021
CIVIL ACTION COVER SHEET INSTRUCTIONS
SELECT CATEGORY THAT BEST DESCRIBES YOUR CASE
AC Actions involving the State/Municipality * ER Equitable Remedies RP Real Property
AA‘ Contract Action invalving Commonwealth, O11 Specific Performance of a Contract (A) C01 Land Taking )
Municipality, MBTA, etc. 02 Reach and Apply ) C02 Zoning Appeal, G.L. c. 404 F)
AB1 Tortious Action involving Commonwealth, 103 Injunction ©) C03 Dispute Conceming Title Fy
Municipality, MBTA, etc. 04 Reform Cancel Instrument ©) (C04 Foreclosure of a Mortgage &)
‘AC1 Real Property Action involving 005 Equitable Replevin F) C05 Condominium Lien & Charges ®
‘Commonwealth, Municipality, MBTA etc. (A) 06 Contribution or Indemnification (F) C99 Other Real Property Action fF)
AD1 Equity Action involving Commonwealth, 07 Imposition of a Trust (A)
Municipality, MBTA, etc. (A) D08 Minority Shareholders Suit (A) MC Miscellanoous Civil Actions
‘AE1 Administrative Action involving D09 Interference in Contractual Relationship (F)
Commonwealth, Municipality, MBTA,etc, (A) D10 Accounting E18 Foreign Discovery Proceeding ©
D11 Enforcement of Restrictive Covenant Fy £97 Prisoner Habeas Corpus (x)
CN ContractiBusiness Cases: 112 Dissolution of a Partnership E22 Lottery Assignment, G. 10.§28 ®
D13 Declaratory Judgment, G.L. ¢.231A (A)
AB Abusalttarassment Prevention
A01
‘A02
‘A03
Services, Labor, and Materials
Goods Sold and Delivered
Commercial Paper
)
F)
D14 Dissolution of a Corporation
99 Other Equity Action a E15 Abuse Prevention Petition, G.L. ¢. 209A _(X)
F) E21 Protection from Harassment, G.L. c. 258E(X)
‘A04 Employment Contract PA. Civil Actions involving Incarcerated Party. t
‘A06 Insurance Contract (F)
‘A08 Sale or Lease of Real Estate (F) AA Administrative
Civil Actions
12 Construction Dispute a) PA1 Contract Action involving an
Incarcerated Party A) E02 Appeal from Administrative Agency,
A14 Interpleador (F) P81 Tortious Action invelving an ©. w
BA1 Governance, Conduct, Internal Incarcerated Party A 03 Certiorari Action, G.L. 6.249 §4
Affairs of Entities (A) ®”
PC1 Real Property Action involving an E05 Confirmation of Arbitration Awards (x)
BAS Liabllity of Shareholders, Directors, Incarcerated Party (F) E06 Mass Antitrust Act, G. L. c. 93 §9 (A)
Officers, Partners, etc. @ PD1 Equity Action involving an E07 Mass Antitrust Act, .L. ©, 93 §8 ®)
8B1 Shareholder Derivative (A) Incarcerated Part E08 Appointment of a Receiver
BB2 Securities Transactions A
(F) (x)
PEt Administrative Action involving an E08 Construction Surety Bond, G.L. c. 149
8C1 Mergers, Consolidations, Sales of Incarcerated Party ) §§29, 298 (A)
Assets, Issuance of Debt, Equity, etc, (A) £10 Summary Process Appeal &)
BD1 Intellectual Property A TR Torts E11 Worker's Compensation )
BD2 Proprietary Information or Trade E16 Auto Surcharge Appeal ®)
Secrets ) B03 Motor Vehicle Negligence - Personal E17 Civil Rights Act, G.L. ¢.12 §11H (A)
G1 Financial Institutions/Funds (A) Injury/Property Damage ) E24 Appeal from District Court
BHI Violation of Antitrust or Trade B04 Other Negligence - Personal Commitment, G.L. 0.123 §9(b) )
Regulation Laws a) Injury/Property Damage (F) E25 Pleural Registry (Asbestos cases)
‘A99 Other Contract/Business Action - Specify (F) BOS Products Liability (A) E94 Forfeiture, G.L. c265 §56 ®)
B06 Malpractice - Medical / Wrongful Death (A) E95 Forfeiture, G.L. ¢.94C §47 F)
B07 Malpractice - Other @) E99 Other Administrative Action ”
* Choose this case type if ANY party is the B08 Wrongful Death, G.L. ¢.229 §2A (A) Z01 Medical Malpractice - Tribunal only,
Commonwealth, a municipality, the MBTA, or any B15 Defamation A) G.L. c. 231 §60B F)
other governmental entity UNLESS your case is a B19 Asbestos (A) 202 Appeal Bond Denial ®
case type listed under Administrative Civil Actions B20 Personal Injury - Slip & Fall fF)
(AA). B21 Environmental (F) ‘SO Sex Offender Review
B22 Employment Discrimination (F)
+ Choose this case type if ANY party is an BE1 Fraud, Business Torts, etc. A) E12 SDP Commitment, G.L. c. 123A §12 &)
incarcerated party, UNLESS your case is a case 899 Other Tortious Action F) E14 SDP Petition, G. ©, 123A §8(b) *”
type listed under Administrative Civil Actions (AA)
oris a Prisoner Habeas Corpus case (E97). RC Restricted Civil Actions
E19 Sex Offender Registry, G.L. ¢.6 §178M )
E27 Minor Seeking Consent, G.L. c.112 §128 (X}
TRANSFER YOUR SELECTION TO THE FACE SHEET
EXAMPLE:
CODE NO. TYPE OF ACTION (specify) TRACK HAS A JURY CLAIM BEEN MADE?
B03 Motor Vehicle Negligence-Personal Injury ~. (yes (no
STATEMENT OF DAMAGES PURSUANT TO G.L. c. 212, § 3A
DUTY OF THE PLAINTIFF - The plaintiff shall set forth, on the face of the civil action cover sheet (or attach additional sheets as necessary), a
statement specifying the facts on which the plaintiff relies to determine money damages. A copy of such civil action cover sheet, including the
statement as to the damages, shall be served with the complaint. A clerk-magistrate shall not accept for filing a complaint, except as
otherwise provided by law, unless it is accompanied by such a statement signed by the attorney or pro se party.
DUTY OF THE DEFENDANT - If the defendant believes that the statement of damages filed by the plaintiff is inadequate, the defendant may
file with his/her answer a statement specifying the potential damages which may result if the plaintiff prevails.
A CIVIL COVER SHEET MUST BE FILED WITH EACH COMPLAINT.
FAILURE TO COMPLETE THIS COVER SHEET THOROUGHLY AND ACCURATELY
MAY RESULT IN DISMISSAL OF THIS ACTION.
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2 [DOCKET NUMBER Trial Court of Massachusetts = CIVIL ACTION COVER SHEET || { | The Superior Court ee | n PLAINTIFF(S): George W. Hodgetts, Individually and as Beneficiary of the Diarra counry Middlesex ADDRESS: 4110 Huntley Apartment Drive, Pelham, Alabama 35124 DEFENDANT(S) Julie Mequade Ladimer, Individually and as Trustee of The emt Dianne Blandon Parents Trust u/d/t 2/3/1997; And as Trusteeof The Dianne Hodgetts a ATTORNEY: ‘Cameron C. Pease Irrevocable Life Insurance Trust u/d/t December 4, 2019 ADDRESS: Goldman & Pease, LLC ADDRESS: Ladimer Law, 209 W. Central Street, Suite 3158 160 Gould St., Ste. 320 sec Natick, MA 01760 ~ Needham, MA 02494 a BBO: 561908 TYPE OF ACTION AND TRACK DESIGNATION {see reverse side) CODE NO. TYPE OF ACTION (specify) TRACK HAS A JURY CLAIM BEEN MADE? A99 Other (specify) FE (lives NO *If "Other" please describe: Trust and Estates ee aint were ee STATEMENT OF DAMAGES PURSUANT TO GL. c, 212, § 3A The following is a full, itemized and detailed statement of the facts on which the undersigned plaintiff or plaintiff counsel relies to determine money damages. For ithis form, disregard double or treble damage claims; indicate single damages only. TORT.CLAIMS. (attach additional sheets as necessary) \A. Documented medical expenses to date: 1. Total hospital expenses 3/25/202. 2. Total doctor expense: 3. Total chiropractic expt 4. Total physical therapy expenses 5. Total other expenses (describe below) RECEIVED Subtotal ( 'B, Documented lost wages and compensation to date ‘C. Documented property damages to dated D. Reasonably anticipated future medical and hospital expenses E. Reasonably anticipated lost wages F. Other documented items of damages (describe below) |G. Briefly describe plaintiffs injury, including the nature and extent of injury: TOTAL (A-F):$ CONTRACT CLAIMS (attach additional sheets as necessary) Provide a detailed description of claims(s): Declaratory Judgment and Breach of Fiduciary Duty in connection with an Irrevocable Trust TOTAL: $ $500,000.00 - - ‘ | Signature of Attorney/Pro Se Plaintiff: a a Date: 3/25/2021 'RELATED ACTIONS: Please provide the case number, case name, and Sounty of any telated actions pending in the Superior Court. CERTIFICATION PURSUANT TO SJC RULE 1:18 | hereby certify that | have complied with requirements of Rule 5 of the Supreme Judicial Court Uniform Rules on Dispute Resolution (SUC. Rule 1:18) requiring that | provide my clients with information about court-connected dispute resolution services and discuss with them the advantages and disadvantages of the various methods of dispute resolution. ‘Signature of Attorney of Record: X ae ani Date: 3/25/2021 CIVIL ACTION COVER SHEET INSTRUCTIONS SELECT CATEGORY THAT BEST DESCRIBES YOUR CASE AC Actions involving the State/Municipality * ER Equitable Remedies RP Real Property AA‘ Contract Action invalving Commonwealth, O11 Specific Performance of a Contract (A) C01 Land Taking ) Municipality, MBTA, etc. 02 Reach and Apply ) C02 Zoning Appeal, G.L. c. 404 F) AB1 Tortious Action involving Commonwealth, 103 Injunction ©) C03 Dispute Conceming Title Fy Municipality, MBTA, etc. 04 Reform Cancel Instrument ©) (C04 Foreclosure of a Mortgage &) ‘AC1 Real Property Action involving 005 Equitable Replevin F) C05 Condominium Lien & Charges ® ‘Commonwealth, Municipality, MBTA etc. (A) 06 Contribution or Indemnification (F) C99 Other Real Property Action fF) AD1 Equity Action involving Commonwealth, 07 Imposition of a Trust (A) Municipality, MBTA, etc. (A) D08 Minority Shareholders Suit (A) MC Miscellanoous Civil Actions ‘AE1 Administrative Action involving D09 Interference in Contractual Relationship (F) Commonwealth, Municipality, MBTA,etc, (A) D10 Accounting E18 Foreign Discovery Proceeding © D11 Enforcement of Restrictive Covenant Fy £97 Prisoner Habeas Corpus (x) CN ContractiBusiness Cases: 112 Dissolution of a Partnership E22 Lottery Assignment, G. 10.§28 ® D13 Declaratory Judgment, G.L. ¢.231A (A) AB Abusalttarassment Prevention A01 ‘A02 ‘A03 Services, Labor, and Materials Goods Sold and Delivered Commercial Paper ) F) D14 Dissolution of a Corporation 99 Other Equity Action a E15 Abuse Prevention Petition, G.L. ¢. 209A _(X) F) E21 Protection from Harassment, G.L. c. 258E(X) ‘A04 Employment Contract PA. Civil Actions involving Incarcerated Party. t ‘A06 Insurance Contract (F) ‘A08 Sale or Lease of Real Estate (F) AA Administrative Civil Actions 12 Construction Dispute a) PA1 Contract Action involving an Incarcerated Party A) E02 Appeal from Administrative Agency, A14 Interpleador (F) P81 Tortious Action invelving an ©. w BA1 Governance, Conduct, Internal Incarcerated Party A 03 Certiorari Action, G.L. 6.249 §4 Affairs of Entities (A) ®” PC1 Real Property Action involving an E05 Confirmation of Arbitration Awards (x) BAS Liabllity of Shareholders, Directors, Incarcerated Party (F) E06 Mass Antitrust Act, G. L. c. 93 §9 (A) Officers, Partners, etc. @ PD1 Equity Action involving an E07 Mass Antitrust Act, .L. ©, 93 §8 ®) 8B1 Shareholder Derivative (A) Incarcerated Part E08 Appointment of a Receiver BB2 Securities Transactions A (F) (x) PEt Administrative Action involving an E08 Construction Surety Bond, G.L. c. 149 8C1 Mergers, Consolidations, Sales of Incarcerated Party ) §§29, 298 (A) Assets, Issuance of Debt, Equity, etc, (A) £10 Summary Process Appeal &) BD1 Intellectual Property A TR Torts E11 Worker's Compensation ) BD2 Proprietary Information or Trade E16 Auto Surcharge Appeal ®) Secrets ) B03 Motor Vehicle Negligence - Personal E17 Civil Rights Act, G.L. ¢.12 §11H (A) G1 Financial Institutions/Funds (A) Injury/Property Damage ) E24 Appeal from District Court BHI Violation of Antitrust or Trade B04 Other Negligence - Personal Commitment, G.L. 0.123 §9(b) ) Regulation Laws a) Injury/Property Damage (F) E25 Pleural Registry (Asbestos cases) ‘A99 Other Contract/Business Action - Specify (F) BOS Products Liability (A) E94 Forfeiture, G.L. c265 §56 ®) B06 Malpractice - Medical / Wrongful Death (A) E95 Forfeiture, G.L. ¢.94C §47 F) B07 Malpractice - Other @) E99 Other Administrative Action ” * Choose this case type if ANY party is the B08 Wrongful Death, G.L. ¢.229 §2A (A) Z01 Medical Malpractice - Tribunal only, Commonwealth, a municipality, the MBTA, or any B15 Defamation A) G.L. c. 231 §60B F) other governmental entity UNLESS your case is a B19 Asbestos (A) 202 Appeal Bond Denial ® case type listed under Administrative Civil Actions B20 Personal Injury - Slip & Fall fF) (AA). B21 Environmental (F) ‘SO Sex Offender Review B22 Employment Discrimination (F) + Choose this case type if ANY party is an BE1 Fraud, Business Torts, etc. A) E12 SDP Commitment, G.L. c. 123A §12 &) incarcerated party, UNLESS your case is a case 899 Other Tortious Action F) E14 SDP Petition, G. ©, 123A §8(b) *” type listed under Administrative Civil Actions (AA) oris a Prisoner Habeas Corpus case (E97). RC Restricted Civil Actions E19 Sex Offender Registry, G.L. ¢.6 §178M ) E27 Minor Seeking Consent, G.L. c.112 §128 (X} TRANSFER YOUR SELECTION TO THE FACE SHEET EXAMPLE: CODE NO. TYPE OF ACTION (specify) TRACK HAS A JURY CLAIM BEEN MADE? B03 Motor Vehicle Negligence-Personal Injury ~. (yes (no STATEMENT OF DAMAGES PURSUANT TO G.L. c. 212, § 3A DUTY OF THE PLAINTIFF - The plaintiff shall set forth, on the face of the civil action cover sheet (or attach additional sheets as necessary), a statement specifying the facts on which the plaintiff relies to determine money damages. A copy of such civil action cover sheet, including the statement as to the damages, shall be served with the complaint. A clerk-magistrate shall not accept for filing a complaint, except as otherwise provided by law, unless it is accompanied by such a statement signed by the attorney or pro se party. DUTY OF THE DEFENDANT - If the defendant believes that the statement of damages filed by the plaintiff is inadequate, the defendant may file with his/her answer a statement specifying the potential damages which may result if the plaintiff prevails. A CIVIL COVER SHEET MUST BE FILED WITH EACH COMPLAINT. FAILURE TO COMPLETE THIS COVER SHEET THOROUGHLY AND ACCURATELY MAY RESULT IN DISMISSAL OF THIS ACTION.